WHAT FARM ORGANIZATIONS HAVE TO SAY

On this page, we have assembled a spectrum of opinions and positions associated with a variety of Canadian Farming Associations. Since policy opinions and positions are subject to change, we have provided the referring link for each of these statements so you may double-check the currency of these excerpts. While it does a disservice to the nuance of policy positions outlined below, a crude assessment of the distribution of published opinions as of Oct. 2013 and presented below are as follows:

FARM ORGANIZATIONS ALIGNED WITH CURRENT PMRA POLICY

Ontario Federation of Agriculture

Christian Farmers Federation

Grain Farmers of Ontario

FARM ORGANIZATIONS SEEKING REVISED POLICY

National Farmers Union

Practical Farmers of Ontario

Ontario Bee Keepers Association

The policy statements follow below.Ontario Federation of Agriculture Collaboration needed to solve bee health problems (2013)http://www.ofa.on.ca/media/news/collaboration-needed-to-solve-bee-health-problemsBy Mark Wales, President, Ontario Federation of Agriculture There’s been a lot of buzz among agricultural and environmental advocates on the state of bees in Canada. That’s because a mysterious condition – called Colony Collapse Disorder (CCD) – has led to the demise of bees in record numbers in recent years. The jury’s still out on exactly what is compromising these colonies, but one thing is certain: industry, government and researchers need to work together to find a science-based solution to solve the problem. Canadian farmers are intimately invested in the health of our land, water, and ecosystems in a way that is unique to our way of life and livelihood. That’s why the subject of sudden bee death is so troubling. Many theories have been suggested as the cause of bee decline. Chief among them is the theory that a class of insecticides called neonicotinoids is to blame. But the issue is complicated. Third-party research on how these pesticides affect bee health has been inconclusive to date, and damage done to bee colonies in close proximity to crops treated with the pesticide is variable. Some eastern Canadian beekeepers have had their hives hardest hit by CCD, while in Western Canada beekeepers have seen less of an impact – even though the pesticides are commonly used across Canada on crops such as corn, soybeans, canola, wheat and vegetables. The Ontario Federation of Agriculture (OFA) is working with key industry and government stakeholders on the newly formed Bee Health Working Group. The group’s mandate is to provide recommendations on how to mitigate the potential risk to honey bees from exposure to neonicotinoid pesticides. While OFA welcomes the opportunity to review solutions to the pressing issue, we also caution against making hasty decisions that could have negatively impact agricultural production and distract from identifying the real source of bee decline. Pesticides – when used appropriately – are an important tool for modern agriculture. All farmers in Ontario who buy and use pesticides must be professionally trained and certified in safe pesticide use, and are required to carefully follow label directions that provide instructions for each product’s safe and proper application. In 2012 Canada’s Pest Management Regulatory Agency (PMRA), responded to concerns about how pesticides impact bee health, and research continues throughout the 2013 growing season. Ontario farmers will await a science-based verdict, and we look to PMRA to use that evidence to mandate what tools farmers can safely access for use on their crops. Ontario farmers have a solid reputation for being quick to adopt new technologies and production techniques. If science concludes that we must find alternative ways to produce safe, quality food in Canada, then we will adapt. But we must avoid impulsive policies that limit a farmer’s access to tools that are key to competitiveness – particularly if we lack the research to back it up. OFA continues to look for our federal and provincial government’s leadership to make informed decisions that impact our ability to operate prosperous and sustainable farms.For more information contact: Mark Wales President Ontario Federation of Agriculture 519-773-6706 Neil Currie General Manager Ontario Federation of Agriculture 519-821-8883The National Farmer’s Unionhttp://www.ontariobee.com/inside-oba/news-and-updates/national-farmers-union-press-release-on-neonicotinoids National Farmers' Union press release on neonicotinoids June 13, 2013Class of pesticides killing Ontario’s honeybees National Farmers Union - Ontario Grey County Local 344 - Media Release Neustadt, ON - Evidence is mounting that a specific class of pesticides is killing Ontario’s honeybees and other pollinating insects in massive numbers. The Ontario Beekeepers Association (OBA), Sierra Club of Canada, The United Church of Canada, and other groups have expressed serious concern about the chemicals and are advocating discontinuing their usage. Pollinators, including honeybees, are a central element of Canada’s food system and a critical pillar of its ecology. The UN Food and Agriculture Organisation estimates that, of the over 100 most common crops which provide 90% of food for 146 countries, 71 are pollinated by bees. But the bees are at risk. In the past decade, extreme declines in bee populations have been measured across North America and Europe, prompting widespread concern from citizens, scientists, and many governments. There are about 80,000 bee hives in Ontario operated by some 250 professional beekeepers and 4,000 hobbyists. The pesticides at issue, called neonicotinoids and manufactured by agribusiness giant Bayer CropScience, have been in use in North America for about a decade. They are typically applied to field corn seed which is widely planted. From the seed the chemicals are taken up by the plant and transported to all its tissues (leaves, flowers, roots and stems, as well as pollen and nectar). The toxin remains active in the plant for many weeks, protecting the crop from aphids, root worms and other insect pests. It attacks insects’ central nervous systems causing paralysis and death. “The problem is, bees and other pollenating insects critically important to Ontario’s economy and food supply are also among the victims,” says Nathan Carey, a member of the Board of Directors of the National Farmers Union-Ontario Grey County Local 344 and a Grey County farmer. While the impact of honeybees extends far beyond the pollination of commercial agricultural crops, the monetary value of this service alone is estimated to be in the hundreds of billions of dollars globally each year. “These dangerous chemicals must be removed from the market now,” said John Bennett, executive director of Sierra Club Canada, quoted in a recent article in the Toronto Star. “We need to protect bees,” he added. Bees transfer pollen and seeds from one flower to another: a crucial natural role that sustains at least 30% of the world’s food crops and 90 per cent of our wild plants. The OBA’s concerns arise from reports from member beekeepers and from data presented by independent research scientists from Canada and around the world. All indicate that neonicotinoids are wiping out entire colonies of honeybees. In 2012, more than 200 bee yards in southern Ontario and Quebec reported an “unusually high number” of losses, according to a recent Health Canada report. An analysis of the dead bees found that approximately 70% of their bodies contained residue of neonicotinoids. In almost all cases, there was evidence of corn planting near affected bee yards. Dave Schuit, owner of Saugeen Country Honey based in Elmwood, said he lost 75% of his hives – an estimated 38 million bees – this past year. He said the losses correspond to the planting of corn on farms near his bee yards. Having sustained such heavy losses Schuit was forced to sell the family farm where he kept his breeding stock of bees. Reflecting on the rate of bee colony collapse in Ontario, Schuit said he fears that “beekeeping will be a thing of the past in two to three years.” In early May the European Union voted for a two-year moratorium on the use of neonicotinoids. In the meantime experts will re-examine scientific studies submitted to obtain approval for the pesticides. The EU’s decision followed a statement in January by the European Food Safety Authority that neonicotinoids potentially reduce bees’ chances of survival. A report by Health Canada’s Pest Management Regulatory Agency (PMRA) says that continued use of neonicotinoids will cause significant reduction in populations of domestic bees, bumble bees or native pollinators; significant decreases in honey production; serious effects on other agricultural systems as a result of decreases in pollination services; a reduction in pollination of wild plants in a way that may alter ecosystems; and the possible loss of a viable beekeeping industry in Ontario. Regardless of these alarming assertions, Health Canada has decided not to suspend or ban neonicotinoids at this time. Tibor Szabo, a beekeeper and vice-president of the OBA, feels Health Canada must ban neonicotinoids: “It’s like a game of roulette now…nothing stops bees from being in contact with pesticides,” he said in the Toronto Star article quoted above. The Sierra Club is calling on Federal Health Minister Leona Aglukkaq to follow the precautionary principle and immediately ban neonicotinoid chemicals Imidacloprid, Clothianidin and Thiamethoxam from use in Canada. The OBA has called for the suspension of neonicotinoids until the risks posed can be better understood. The United Church has called for a moratorium on neonicotioids for the same reason. For more information contact Nathan Carey (519-665-7305) or Gary Kenny, Media Liaison for NFU-O Grey County Local 344 (519-799-5804). -30- Editor's Note: See the NFU-O's article in the July issue of the Rural Voice for more information on neonicotinoids

Christian Farmers Federation of Ontario

http://www.christianfarmers.org/images/Policy/polneo.pdfThe CFFO on Pollinators and Neonicotinoids Background What is the Issue? Extensive pollinator deaths through the spring of 2012 in areas of southern Ontario have been attributed to the use of neonicotinoid (neonic) pesticides. It is unclear if this will be a continuous issue, or whether it was a unique “perfect storm” created by the highly unusual circumstances of spring 2012. The exceptional circumstances include an unusually warm spring in 2012, wherein farmers were planting crops 3 weeks earlier than normal. Secondly, hives suffered fewer overwintering losses than normal, encouraging increased activity. Finally, dust travelled further than normal because of the dry, windy conditions.On what is happening within the industry:

Several steps have been taken by industry to improve communications on this issue: Labelling will be improved in 2014 onward, speaking to the impact of the active ingredient on bees.

Health Canada has published an advisory on reducing risk from treated seed covering a wide range of potential concerns. These include:

communication between farmers, custom seeders, and beekeepers

be aware bees can forage 5km from their hive

control flowering weeds prior to planting so foraging bees are not attracted to the planting site

properly dispose of any dust or treated seed remaining in planting equipment

do not leave empty bags or left-over treated seed in fields or hedgerows

participate in seed bag collection programs where available

Crop protection companies are working at technical solutions to reduce dust and drift issues, including

seed coating formulations to reduce abrasion,

seed flow lubricants that produce less dust than talc,

ISO standards on fugitive dust from planting equipment (2015)

a pilot program on disposal of treated seed bags.

Finally, the Pest Management Regulatory Agency (PMRA) sent a clear warning to industry that a failure to reduce dust related incidents may force additional regulatory measures. On our consultations with the membership: This issue was discussed at our stewardship and policy meetings at the end of March. It should be noted that at this time, it was unclear to what degree neonics impacted the number of deaths, although the exceptional circumstances were recognized. The clear message from the active grassroots of CFFO, notwithstanding a small minority, was to support efforts to mitigate the impact of neonics on pollinators (management, communication, technology), and overwhelmingly rejected the proposition of discontinuing the use of these products at this point in time.

The prosperous future of Ontario agriculture is in large part dependent on our willingness to adapt to new technology, innovation, and productivity improvement. There is no doubt that unintended consequences will occur, and there is no doubt that they will have to be addressed. It is a matter of “how” they are addressed that matters. Other Considerations: Up to this point in time, the primary consideration has been the impact on the commercial bee business, and evidence has been collected that focuses on the impact in this area. However, the impact on broader biodiversity will need to be considered as we move forward. The impact on wild pollinators, other benign insects and the animals (birds) that feed on these pollinators will need to be considered going forward. It should also be noted that many greenhouses have moved towards adopting “integrated pest management” systems that utilize benign insects as deterrents in a closed environment rather than use of chemicals. They have learned to use nature as an ally in a cost effective manner.

There are growing concerns about the presence of neonics in soil, its solubility in water and its transference to surrounding (non-agriculture crop) plants will have on-going detrimental impacts to the natural world, a system upon which agriculture ultimately depends. Moreover, the half-life of these products creates a long-term concern around its impact.CFFO Position on the Pollinator and Neonic Issue The CFFO supports the following as the appropriate next steps on the pollinator-neonics issue: 1. Managing the threat: The development, introduction, and dispersal of best management practices to minimize the impact of neonics on pollinators. 2. Using technology to reduce the threat: The development of technology that reduces dust emission through a variety of means.3. Continuous monitoring of bee losses throughout the province.4. Research into the impact on wild pollinators, benign insects and animals will need to be conducted. 5. Research into the broader impacts on surrounding plants, water contamination, and soil health will need to be conducted. 6. Research into the merits of applying “integrated pest management” principles in an open environment situation to reduce or replace insecticide use.At this time, the CFFO is not asking for:1. A blanket banning of the use of neonics. However, the CFFO will continue to monitor the situation while being prepared to reconsider its position if the trend continues to grow and pollinator losses accelerate or if evidence of water, soil and plant contamination continues to grow. Adopted by CFFO Provincial Council June 26, 2013

Bees are dying in massive numbers due, in part, to the pervasive and routine use of neonicotinoid pesticides, regardless of insect pest levels. Fully a third of our food relies on pollinators: without bees, Canada’s food supply, food security, and food sovereignty would be in serious trouble. Further, these chemicals leach into soils, groundwater and waterways, persisting for years, potentially killing and harming not only bees, but other pollinators, aquatic insects, amphibians and birds.

We already have sufficient evidence to prove that neonicotinoid pesticides are killing our bees. Canada’s Pesticide Management Regulatory Agency, a part of Health Canada, has confirmed that widespread bee deaths in Ontario were caused by neonicotinoid pesticides. As well, many independent, peer reviewed scientific research studies have concluded that these pesticides pose a significant threat to bees and other wildlife. Furthermore, science and experience have shown that use of neonicotinoids provide minimal increase in agricultural yield in the long run.

Principles

1. The health, efficiency and outcomes of our food systems are intrinsically linked to the health of pollinator populations.

Many of the foods we eat are directly pollinated by insects including apples, blueberries, broccoli, carrots, sunflower seeds, almonds, citrus and many, many more. Even foods such as milk, cheese, ice-cream and other dairy products owe their production to pollinating insects that pollinate alfalfa, the main constituent of hay. Without pollinators our agricultural sector would face economic hardship, our diets would decline dramatically and our quality of life would suffer immeasurably.

2. For pollinator populations to thrive we must create, encourage and protect vibrant, bio-diverse ecosystems in both urban and rural areas.

If we are to have a strong and robust population of pollinators we must ensure that the environment supports them. Toxins must be low to non-existent and food sources must be abundant and diverse. This is accomplished by encouraging the planting of native flowering plants wherever possible, leaving tree-lines and hedge-rows intact in agricultural areas and protecting existing pollinator habitat. 3. Chemical pesticides should only be applied for acute problems and not applied routinely as a preventative. New, non-toxic methods for pest control must be developed and encouraged.

While pesticides are toxins designed to kill they may be a useful tool in a healthy agricultural system if they are used sparingly and only when needed. Integrated Pest Management (IPM) practices should be followed for any pesticide application. Many farmers do not use pesticides to manage pest pressure and instead follow organic, bio-dynamic or other techniques to safely manage pests in a way that does not interfere with the integrity of eco-systems that pollinators (and humans!) depend on.

PURPOSE 1. To ensure that regulators immediately reassess the bee and pollinator safety of all neonicotinoid pesticide products and suspend all conditional registrations until we understand how to manage the risks posed by these products to honey bees, other pollinators and other wildlife including birds and amphibians. 2. To ensure that beekeepers are compensated for losses caused by deaths, chronic disease, or toxic residues in equipment resulting from neonicotinoid pesticide products beginning in the crop year 2012 and going forward. 3. To ensure that independent research is undertaken to determine threats of neonicitinoid use on long-term soil, water and air-borne toxicity and pollinator health and whether the substitution of less toxic pesticides, integrated pest management practices and/or organic farming practices can eliminate the pesticide’s impact on honey bees and other pollinators 4. To ensure that habitat for pollinators is created and maintained throughout the urban and rural landscape by promoting planting of native plants wherever possible and by protecting existing habitat.COMMODITY ORGANIZATIONSGrain Farmers of Ontariohttp://www.gfo.ca/protectingpollinators.aspx

Grain Farmers of Ontario is the province’s largest commodity organization, representing Ontario’s 28,000 corn, soybean and wheat farmers. The crops they grow cover 5 million acres of farm land across the province, generate over $2.5 billion in farm gate receipts, result in over $9 billion in economic output and are responsible for over 40,000 jobs in the province. The end uses for the crops include food, fuel, plastics, medicine, and many other essential products used daily across the province. Following a decrease in the bee population in 2012, concerns have been raised over a specific class of pesticide (neonicotinoids) and grain farming practices. The following information is intended to clarify details around some of the most common questions.

About Neonicotinoids Neonicotinoids were introduced in the late 1990s and were widely adopted as the safest seed treatment with excellent results by 2003. It is important to note that the major decline in bee population took place last year. The Pest Management Regulatory Agency launched a re-evaluation of neonicotinoids in June 2012. There continues to be emerging science on neonicotinoids and their potential effects on pollinators. The PMRA is collaborating with international regulatory partners to discuss further data requirements and in the development of enhanced risk assessment methodologies and risk mitigation measures for pollinators. The PMRA is committed to only registering pest control products that meet stringent health and environmental standards and do not pose unacceptable risks. Details about this evaluation can be found at: http://www.hc-sc.gc.ca/cps-spc/pubs/pest/_decisions/rev2012-02/index-eng.php. •Is Grain Farmers of Ontario concerned about the bee population?

Should farmers be continuing to use neonicotinoids? The Pest Management Regulatory Agency (PMRA) regulates pesticides and has deemed neonicotinoids safe. This year, the PMRA initiated changes to treated seed bag labels and tags to ensure proper handling and application practices are adhered to. Labelling changes, to alert growers and applicators to the potential hazard treated seed dust can pose to bees and best management practices to be employed during planting, have been implemented in 2013 such that neonicotinoid treated corn seed entering the market place for the 2014 growing season is labelled with the appropriate statements. Significant effort has been invested in 2012 and 2013 to develop detailed best management practices for planting neonicotinoid treated seed to mitigate risks to pollinators. These guidelines can be found here: http://www.hc-sc.gc.ca/cps-spc/pubs/pest/_fact-fiche/pollinator-protection-pollinisateurs/index-eng.php#a6. Neonicotinoid seed treatments are an important tool for Ontario’s grain farmers. Without this technology, Grain Farmers of Ontario estimates a significant reduction of yield and loss of income for our farmers. The success of our crops is critical not only to the farmer’s bottom line, but also to livestock producers, the food ingredient industry, the renewable fuels industry, the bio-products industry, and many other downstream users. The impact of reduced yield would be felt across the province. •Ontario Bee Producer’s Association